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Strategic IT planning for compliance and beyond

by Dennis C. Brewer

Regulatory compliance places demands on corporate businesses, but regulations like HIPAA, GLBA and SOX also provide an opportunity for strategic IT planning across the entire business. This article tells you how.

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initiatives from the business units typically undergo a review process to obtain funding. But rarely is there a parallel process of evaluation for technological conformity with the enterprise's overall IT architectural vision. As a result, enterprises quickly comply with current regulatory demands at the cost of strategically preparing themselves for the next wave of regulatory requirements.

Technology planning in the ever changing landscape brought about by compliance requirements tends to be reactionary rather than a continuous, proactive process driven by the overall IT needs of the business. As a result, planning efforts are seriously lacking in continuity and conformity. The IT planner's focus for design and transition efforts should develop within the context of three time frames: first, what is on the ground today; second, what will be needed to comply or meet objectives in the near term; and, even if based on speculation, what is likely to be needed immediately after the near-term need is fulfilled. The goal is to implement improvements that satisfy the near-term needs and at the same time position the enterprise to meet the next potential challenge before it arrives.

Let's look, for example, at a hypothetical national health care provider. The health care provider has a few local branches located in a state with additional HIPAA-like requirements for access controls above and beyond the national regulation. Reacting to immediate regulatory demands, the local branches jointly purchase thumb print readers to

include bio scan for authentication to patient data. The thumb print solution may work, but the national corporation could take this opportunity to develop across all branches a token card solution tied to service directories. The correct approach is to use the local branches as the test bed or early roll out for the corporate
token cards.

The actual future condition achieved by implementing IT systems and solutions can be summarized in the statement: Your collection of daily tactical decisions equal tomorrow's strategic reality. A single, narrowly focused, incomplete approach to planning IT with emphasis only on achieving compliance falls far short of what could be achieved if a comprehensive planning scope is the cultural norm. Certainly new legal compliance requirements are a priority that cannot be ignored; however, these challenges should not dominate the use of corporate IT resources to the detriment of other qualitative improvements.

Reacting to new compliance initiatives in this manner also fails to provide the impetus for capitalizing on opportunities (such as funding) that can only be realized when technology opportunities are viewed across the entire enterprise. Treating planning only in a reactive manner downplays the potential for leading corporate directors or the governance committee to embrace the more promising enterprise-ready emerging technologies or leverage those already proven elsewhere. If the hypothetical heath care company used the locally-imposed time pressure to their advantage and used those branches as a proving ground to implement the authentication servers and directories needed for a universal token card authentication model, not only would they have prevented a wasteful duplication of functions, they would have met a strategic objective more rapidly.

Recommendation

To move from reactionary to proactive planning, manage the strategic planning function by focusing equal and concurrent attention in the following five distinct planning areas of opportunity with defined timelines and objectives:

Plan for new applications and projects by correlating them with management's vision and business-driven initiatives, such as entering new markets or introducing new product lines. These initiatives may often simply result from changes in law and organizational structure. They may also represent opportunities to use technology to improve delivery of services or garner cost savings though efficiency from modification of underlying business processes.

Rationalization planning focuses on all current information technology operations throughout the enterprise, seeking opportunities to reduce both the fixed and variable costs of all current operations of existing hardware, software, communications and human resources used to deliver technology today without compromising current or future functionality.

Quality improvement opportunities exist across the IT spectrum to provide measurable efficiencies to the end user community by creating and implementing plans that lead to improved management of the resources previously deployed.

Planning must include action items resulting from systems and applications risk reduction analysis that focuses attention on anticipating and mitigating through pre-planning and preparation for the next potential information technology crisis regardless of causal source (hackers, homeland security breaches, disaster recovery realities, etc.).

Enterprise-wide value-added initiatives concentrate on initiating and finding funding for projects, or alternative features within planned projects or existing systems, that will increase the efficiency or reduce management burden of technology, processes, services, and systems, that benefit two or more divisions, or the entire enterprise.

The development challenge is to use planning to shape today's tactical uncertainty into tomorrow's strategic reality in a way that every stakeholder can feel some ownership and derive some pride from his or her contributions to the end results. One approach is to hire a single individual to be responsible for a technology planning office and oversee strategic improvement processes within a comprehensive approach as presented here -- fine tuned as needed by guidance from you and your board of directors. This office and its staff must have the characteristics that make the leader and staff members suited to such a challenging leadership position includes an ability to operate on three intersecting planes. The first surface is the ability to bridge from today's reality to visionary; knowing what could be at the futuristic level, and at the same time being capable of delving into and understanding the difficulties inherent in the most technical implementation nuts and bolts details. The next surface requires an experienced reference to the past performance, present condition, and future possibilities for changing technology. The third surface is the ability to translate and communicate the appropriate message to audiences at all levels in the organization, with an awareness and appreciation for judiciously articulating the need for managed change across the full spectrum from politically popular ideas all the way to less exciting yet practical and very necessary ones.

Each of these five planning areas is deserving of management attention at the highest levels and if orchestrated properly can yield results far beyond any near-term compliance schedule.

About the author Dennis C. Brewer is the author of Security Controls for Sarbanes-Oxley Section 404 IT Compliance: Authorization, Authentication and Access published by Wiley. His resume includes a BSBA degree from Michigan Technological University, Novell Network Engineer Certification, and over a dozen years as an information technology specialist with the State of Michigan. He retired from his position as an IT security solutions specialist in January of 2006 from the State of Michigan, Department of Information Technology, Office of Enterprise Security and is now operating his own IT consulting practice in Laurium, Michigan.

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